Anti-Money Laundering (AML) Policy

International Commercial Bank (ICB)

1. Introduction

International Commercial Bank (ICB) is committed to maintaining the highest standards of financial integrity and preventing its services from being used for money laundering, terrorist financing, and other illicit financial activities. This Anti-Money Laundering (AML) policy outlines the framework for compliance with local and international regulations, ensuring that ICB operates within legal and ethical boundaries.

2. Regulatory Compliance

ICB adheres to the AML laws and regulations of all jurisdictions in which it operates, including but not limited to:

• The Financial Action Task Force (FATF) recommendations
• Local central bank regulations and financial crime laws
• International Investment Consortium (IIC) compliance guidelines

ICB ensures that its policies align with global best practices, including Know Your Customer (KYC), risk-based due diligence, and transaction monitoring.

3. Customer Due Diligence (CDD) & Know Your Customer (KYC)

ICB follows a robust KYC process to verify the identity of customers before establishing any financial relationship. The key components include:

• Customer Identification: Collection and verification of identity documents (passport, national ID, utility bills, etc.).
• Risk-Based Approach: Classification of customers based on their risk levels (low, medium, high).
• Enhanced Due Diligence (EDD): Applied to high-risk customers, such as politically exposed persons (PEPs) and businesses in high-risk industries.
• Ongoing Monitoring: Continuous assessment of transactions to identify suspicious activity.

4. Transaction Monitoring & Reporting

ICB has a system in place for monitoring customer transactions to detect and report suspicious activities. This includes:

• Automated and manual transaction monitoring
• Red flags for unusual transaction patterns
• Immediate reporting of suspicious transactions to regulatory authorities
• Compliance with reporting obligations for large or unusual transactions

5. Record Keeping

ICB maintains all customer records, transaction data, and compliance reports for the required period as per regulatory guidelines. These records include:

• Customer identification documents
• Transaction history and risk assessments
• Reports on suspicious activities

6. Training & Awareness

ICB ensures that its employees are well-trained in AML procedures. This includes:

• Regular training sessions on detecting and preventing money laundering
• Awareness programs on regulatory updates
• Testing and certification for compliance personnel

7. Sanctions Compliance

ICB strictly adheres to international sanctions lists, including those issued by:

• The United Nations (UN)
• The Office of Foreign Assets Control (OFAC)
• The European Union (EU)
• Local regulatory authorities

ICB ensures that no business relationship is established with sanctioned individuals, entities, or countries.

8. Internal Controls & Independent Audit

• ICB implements strong internal controls to detect and prevent financial crime.
• Independent audits are conducted to assess AML compliance.
• The compliance team regularly updates policies to align with changing regulations.
• Senior management ensures strict adherence to AML policies.

9. Non-Compliance & Penalties

Any employee or customer found violating AML policies may face disciplinary action, account suspension, or legal penalties. Non-compliance with AML laws may result in severe regulatory sanctions for ICB.

10. Conclusion

ICB is committed to financial transparency and preventing illicit financial activities. This AML policy serves as a cornerstone of our compliance framework, ensuring a secure banking environment for all stakeholders.